That new GDC survey in full

Even in the depths of the Cotswolds, you could hear the groans of cynicism from dental professionals as a new survey inspired by the General Dental Council’s relentless desire to question the UK dental sector’s professionalism, hit their electronic inboxes last week.

The email had the strapline “Opportunity to contribute to GDC Survey on professional behaviour” and is a survey funded by the General Dental Council. The work is being undertaken by the Association for Dental Education in Europe (ADEE) and the survey is being run by Cardiff University.

If you are so taken, you can fill it in reasonably assured that your email address and response is safe in Cardiff University’s hands, rather than the hands of the ‘oopsy’ GDC, but more of that later.

According to the introduction to the survey, the primary aim of the study is “to identify the boundaries of professional behaviour for dental professionals” including dentists, nurses, hygienists, therapists and technicians.

The organisers of the study are seeking responses from UK-based dental professionals, dental educators and the general public and the ‘lucky winners’ from round one of the survey will be invited to rounds two and three. Cardiff researchers say that the study uses established research methods to find areas of agreement amongst participants – so presumably anyone who disagrees with the notion that all naughty registrants should be horsewhipped if they transgress professional ‘norms,’ will be thrown out of the survey…but I wouldn’t bank on it.

During the first round of questions, participants are given a range of statements to consider and are asked to rate whether they feel the behaviour in question is ‘professional.’

In the second round, it is intended to only ask participants to look at statements where there ‘wasn’t agreement.’ I took this to mean no agreement with the majority. Participants will again be presented with an anonymous summary of the responses from all other respondents. They will then be invited to reassess their answers in the light of responses from other participants, and respond again.

Now if that isn’t peer to peer coercion, I don’t know what is.

Looking through the questions in this survey, I was reminded of something I saw back in 1973 and stuck with me all these years. I was working as a provincial journalist and one of the young junior reporters who had just moved to the paper from up North, was looking for a female companion. He was having a little bit of a struggle because he looked a tad like the resulting product had Arthur Mullard spawned a love child with Mick Hucknall, so it was all stacked against him.

Back in those days there was no internet dating of course and the main ‘dating by post’ company was (I think) called Dateline. There was quite an extensive questionnaire and questions were fairly innocuous like “What is your favourite colour?” and “Do you prefer dining out to badger-baiting?” – that sort of thing. But among trite questions such as “Do you prefer blondes to gingers?” came the question “Do you believe that communism is a vice that should be eradicated from the face of the Earth?” Wow. What a question. I had that same feeling when I looked through this survey.

So, what, exactly, are respondents being asked in this questionnaire?

Under the heading “What does professionalism mean for members of the dental team?” participants are asked: is “Having straight, unstained teeth” Not necessary, Desirable or Essential?

I mean, mine aren’t stained, but they are certainly not straight, so was I being unprofessional for not signing up for an online brace? Would I be hauled in front of a committee if I had an imbricated UL2?

 

 

Another doozy was, is “Making decisions on the basis of patient need, not financial reward?” Not necessary, Desirable, or Essential?

I would challenge if asking this question is necessary? I can’t think of any reasonable human being, let alone a dental professional would tick ‘Not necessary.’

One question asks ‘Is it essential, desirable or not necessary to consistently see patients on time.’ This is surely putting a cat among the pigeons. A few public respondents that tick ‘essential’ could tip the balance and you could find yourself in the future in front of a Professional Conduct Committee on a charge of ‘mild tardiness.’ This would mean most NHS dentists, hygienists and therapists and a good number of private practitioners, would find themselves with conditions placed upon them, like a rocket up the bum, to encourage them to keep on time.

A really quite explosive question asks if it’s not unprofessional, moderately unprofessional or highly unprofessional if you are severely depressed and don’t see a doctor about it.  

WHAT???

This could have profound consequences for, I suspect, a reasonable proportion of the 11% of dentists who are thought to suffer from depression and yet don’t seek treatment for fear of attracting sanction and work restrictions from the authorities. Could the GDC seriously put this into their guidelines? That would be turning a medical problem into a professional conduct charge. I personally, wouldn’t put it past them.

 

It’s actually really difficult to hazard a guess at what the GDC is hoping to learn from this study. I would have thought most unprofessional acts will have already been logged and put in the little black GDC book of “Things to throw at ‘em while we’re at it.’

An esteemed colleague is similarly nonplussed. He feared a situation where the GDC could adopt extra suggestions of transgressions and hold them against the profession.

“The profession (is) being asked to decide what is naughty so that the GDC can hold you to account in the future. They will (then) tell you it’s your fault ‘cos the profession said it’s naughty.”

Another clinician compared the survey to “Turkeys designing Christmas.” He added “This regulator can’t be trusted.”

Among other questions that really invited the response “Erm…DUH” asked if it was unprofessional to curse and swear within earshot of patients, whether it was a bit off to make sexual advances to a patient in the workplace, whether it was unprofessional to provide non-essential antibiotics at a patient’s request and was it unprofessional for dental professionals to have visible tattoos or facial piercings?

A slightly Big Brother note in the survey was one that asked participants what they think of dental professionals drinking to excess in a public bar when working or not working the next day. If that’s not designed to discourage dental people from drinking socially, I don’t know what is. Presumably, it’s ok to drink at home? Well no it isn’t. An opinion is sought on whether getting drunk when working the next day is professional or not. The effect of the first two questions, if adopted by the GDC, could cause people who like to imbibe a perfectly legal substance in a social setting, to go ‘underground’ and become ‘secret’ drinkers for fear of being deemed unprofessional if they get merry in public. And if you fancied substituting a ciggy for your favourite tipple, the survey also asks if smoking during the working day is desirable and professional behaviour.

In my view, if you were to exclude dental professionals who had tattoos or facial piercings, half the staff at the last practice I worked at would have been on the dole – and that includes dentists. I am personally not a fan of tattoos – but if I did have one, it would be “Who Has Half-Inched My Willis Gauge Again???” inscribed in blood red, on my inner thigh. Some of the most reliable, brilliant people I have ever worked with have either had facial piercings or tattoos. If the GDC didn’t consider tattoos or piercings as a potential problem, why even include the question in the survey?

Having seen some of the incidents related to the GDC over the past couple of months or so, I do believe this organisation is capable of adopting the most preposterous of suggestions.

The idea of it being highly unlikely that the GDC will make it an ‘offence’ to accept ‘friend requests’ from patients on social media, is something I would dismiss as fantasy. I wouldn’t put anything past the GDC at the moment.

 

 

The GDC has relatively recently been caught out using private detectives to ‘entrap’ registrants and withholding evidence from its own Professional Conduct Committee which enabled a fraudulent dentist to be erroneously reinstated to the dental register (the GDC was actually taken to the High Court for that one).

Then there is the ongoing and controversial case of the GDC continuing to allow overseas dentists outside the EU to register as dental therapists without taking the Overseas Registration Examination (ORE), despite the high failure rate by overseas dentists in this exam. When a GDPUK journalist broke the story a few weeks ago, the GDC said there was no ‘evidence’ that there was a safety issue and therefore the registration rules wouldn’t be altered, despite there being growing anecdotal concerns regarding the skills of dentists qualifying outside the EU. It’s only this week, again after the GDPUK approached the GDC, that they have agreed to meet with representatives led by the British Association of Dental Therapists to discuss their concerns.

 

 

Despite the GDC’s proclamation in its ‘Shifting the balance: a better, fairer system of dental regulation’ document, that “Good regulation starts ‘upstream’ with communications, engagement and learning; persuasion and influence; leadership, partnership and an expression of common goals,” the GDC does often come across as being institutionally intransigent.

This is best illustrated following publication of The Professional Standards Authority’s (PSA) 2017/18 GDC Performance Review. The PSA found the GDC did not meet fitness to practise standards 6 and 10

With regard to Standard 10, where information about fitness to practise cases is securely retained, the GDC did not meet this standard this year. In the previous year, the standard was not met because of a number of serious data breaches.

That’s right. Serious data breaches. 

Oopsy!

Despite the GDC taking action in relation to its information security, the GDC still reported five data breaches to the Information Commissioner’s Office (ICO) over the 2017/18 performance review period, which is an increase on the previous period, when two breaches were reported.

The PSA was concerned that in three out of the five data breaches, the GDC did not identify the breaches itself and was instead notified of them by external individuals. The ICO apparently deemed that no further action was necessary, but the GDC did not meet the PSA’s standard 10 for the past four performance reviews.

Ian Brack is the Chief Executive and Registrar of the GDC. He has overall responsibility for the operational activity at the GDC. In June of this year, Mr Brack responded to the SRA’s report.

“With regards to standard 10, we have undertaken significant work to develop and implement a robust information governance framework and ensure a high level of compliance with the requirements of the new General Data Protection Regulation.

While we note the PSA's findings about the increase in the number of referrals to the Information Commissioner (the ICO), we disagree that this means our performance against this standard has declined.”

Mr Brack argued that because the GDC embraced ‘openness’ in reporting breaches, the increase in reports had become a reason for censure within the PSA’s framework.

Mr Brack also said: “It is also concerning that the PSA should have concluded that external validation is essential, as such a view is also at odds with that of the ICO.”

In short, the GDC didn’t accept the findings of the PSA, its regulator and actually quietly criticised the PSA.

Ironically, the survey asks if it is not necessary, desirable, or essential to deal with accidental breaches of confidentiality immediately and informing patients. Remember? The GDC had to be told of some of the breaches they had committed.

At the time of writing, GDPUK was unable to confirm who authored the questions in the survey – whether the questions were posed by Cardiff University, ADEE or the GDC itself. If the questions were set by GDC, then watch out!

There is one slight hope that the GDC may not act on the results of the survey. A reporter who worked on the overseas dentists’ story for GDPUK a few weeks ago, tells of how the GDC is absolutely convinced and unshakeable in its belief that its processes in registering overseas dentists without further examination, is ‘robust’ and beyond criticism. In that case, they may not take suggestions from the profession or the public seriously.

That hope is squished like a bug though, when you consider the General Dental Council is actually funding the study and its probable that the GDC had a significant input into the questions, bearing in mind it did so in the Registrant Survey 2017-18.

What do you think? Why not go online? There’s apparently, a survey you can do. It should ask: Do you think the GDC should have reduced the Annual Retention Fee a teeny bit more, bearing in mind they have the spare dosh to carry out these sorts of surveys?

Just don’t tell social media you filled it in.